I am having trouble finding any training on foreclosures for bank employees. Do you know of any on-line or seminar training that is available to employees?
Do we have to/should we have our clients sign/acknowledge that they received a copy our our new Privacy Notice that went into effect 2010? My question stems from a recent FDIC exam.
There was a technical error on the initial disclosure. The amount of insurance and taxes were understated and the total amount was incorrect. Is this a RESPA violation? If so, is there a cure provision?
Because of the HPML escrow requirements, our bank is just getting started with escrow. Do you have any advice for procedures and getting the system in place?
Are there any changes being made to the application associated with the new RESPA changes?
If a "seller/lender" truth in lending disclosure (with total sale price) is required, and a standard TIL is provided, is there a cure?
Is it required to show proof of training for AML-BSA and/or regulatory compliance? If it is, where is the requirement identified?
What is the difference between a co-signer, co-maker, co-applicant, guarantor and endorser?
We have a borrower who is a member of the Army National Guard. It is my understanding that he now has the same rights as regular Army members as far as the SCRA is concerned regarding the 6% loan interest rate. The service member received orders dated 5/14/08 to report to active duty for training beginning 7/28/08 until a specified time. Then he received orders on 7/15/08 for temporary duty for one day on July 26th. On July 18th he received an order to active duty as a member of his Reserve Component Unit for a period beginning 9/6/08. Does his period of duty begin on May 14th when the first order for training came or July 18th when he received final orders?
One of our branches made a multiple advance consumer purpose loan to purchase and renovate an existing home that the borrowers will move into after renovation. At the time the loan was made, the branch had (and still has) a commitment letter for permanent financing from another lender. Per HMDA guidance "The regulation lists as examples of temporary financing construction loans and bridge loans. See 203.4(d)(3). Construction and bridge loans are illustrative, not exclusive, examples of temporary financing. The examples indicate that financing is temporary if it is designed to be replaced by permanent financing of a much longer term. A loan is not temporary financing merely because its term is short. For example, a lender may make a loan with a one year term to enable an investor to purchase a home, renovate it and resell it before the term expires. Such a loan must be reported as a home purchase loan. See 203.2(h)." Therefore, because of that outside commitment letter, we determined that it was not HMDA reportable. However, since it is a loan to purchase an existing dwelling that will be occupied by the applicant as a primary dwelling, is monitoring information required under Reg B? I have been told that for monitoring purposes, we have two tests to fulfill, the HMDA test and the Reg B test. We already know this is temporary under HMDA and not HMDA reportable, but I'm not sure if I need monitoring information under Reg B. Specifically, 12 CFR 202.13 states that a bank must get monitoring information for dwelling purchase loans or refinancing of a purchase money loans. It appears, based on what I have been told before, that only the initial construction of a home is exempt under Reg B for monitoring purposes. From past training, I seem to recall that other temporary loans, such as bridge loans and the loan in question, are still covered by the monitoring information requirements of Reg B since they are to purchase an existing dwelling. Is that correct or can I use the same temporary financing test for HMDA and Reg B?